International Traffic in Arms Regulations: Are you ITAR Compliant?

International Traffic in Arms Regulations (ITAR) is a set of U.S. Government regulations that requires all manufacturers, exporters and brokers of defense articles, defense services or related technical data to be ITAR compliant. If your company falls under these categories, the following information will help answer some of your questions as to whether you need to become ITAR compliant and how to go about it.​

The first thing you should do to determine whether you need to become ITAR compliant is to download “Getting Started with Defense Trade (refer to: http://www.pmddtc.state.gov/documents/ddtc_getting_started.pdf). The document provides a quick action checklist to determine if export controls apply to you. Here are a few of the points covered:

Category II: Guns and armament (guns over caliber .50 and flame throwers specifically designed or modified for military application, for example).

Category III: Ammunition/ordnance (components, parts, accessories, attachments and associated equipment specifically designed or modified for the article in this category, including, but not limited to, cartridge cases, power bags (or other propellant charges), bullets, jackets, cores, shells (excluding shotgun shells) and other detonating devices for the defense articles controlled in this category, for example).

This is typically a precondition to the issuance of any license or other approval measure. Here’s some clarification as to what each of these means:

1. Registration: Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with the Directorate of Defense Trade Controls (go here to learn more: http://www.pmddtc.state.gov/registration/). According to the U.S. State Department, registration is primarily a means to provide the U.S. government with necessary information on who is involved in certain manufacturing, exporting and brokering activities. Registration does not confer any export rights or privileges but is a precondition for the issuance of any license or other approval for export.

The period of validity for new and renewal registrations is 12 months from the date of issuance.

2. Fees: The set fee for new registrants is $2,250 (manufacturers/exporters and brokers). However, persons registering as a manufacturer/exporter may also simultaneously register as a broker with a consolidated DS-2032 Statement of Registration and not be charged a separate broker registration fee. Do it right the first time on your registration. Registration fees are nonrefundable.